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IN THE CIRCUIT COURT OF THE
15 th JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
JP MORGAN CHASE BANK, NATIONAL CASE NO.: 50 2008 CA 00 2301 XXXXMB
ASSOCIATION, AS TRUSTEE, - Division: AW
Plaintiff,
vs.
GIUSEPPE MANNARINO, et al,
Defendants.
/
DEFENDANT, GIUSEPPE MANNARINO, ANTHONY MANNARINO, MARIA
MANNARINO, AND DANIELLE MANNARINO’S MOTION TO DISMISS PLAINTIFF’S
COMPLAINT
MOTION TO porte LIS PENDENS
COMES NOW, the Defendants, GIUSEPPE MANNARINO, ANTHONY MANNARINO,
MARIA MANNARINO, and DANIELLE MANNARINO (hereinafter “Defendants”), by and
through their undersigned attorneys, hereby files this their Motion To Dismiss Plaintiff's Complaint
and Motion To Dissolve Lis Pendens filed by JP MORGAN Chase Bank, National Association, As
Trustee and in support thereof states as follows:
He On or about March 8, 2008, the Defendants were served with Plaintiff, JP MORGAN
CHASE BANK, NATIONAL ASSOCIATION, AS TRUSTEE’S, two-count Complaint.
See Complaint attached hereto as Exhibit “A”.
2. That Count I of the Plaintiff's Complaint seeks the reestablishment of a promissory note,
purportedly executed by the Defendant, GIUSEPPE MANNARINO.
3. That Count II of the Plaintiffs Complaint seeks to foreclose a mortgage on real property
owned by the Defendants, located in Palm Beach County, Florida.
4. That Plaintiff's Complaint should be dismissed in its entirety, since the Plaintiff has failed to
allege its capacity and furthermore, it can not be determined in what state it is incorporatedthereunder. There is no such corporation listed in Florida, within the Department of State,
and if the Plaintiff is a foreign corporation, it must pay the Clerk a fee as a condition
precedent to instituting this action. Since, to the best of the undersigned’s knowledge,
Plaintiff has not done so and as such, is in violation of Florida Statutes.
5. That Count I of Plaintiff's Complaint should be dismissed on the basis that Plaintiff has not
properly established current ownership and possession of the Promissory Note on which
- Plaintiff is not seeking relief. This is evident due to Count I in the Plaintiffs Complaint for
reestablishment of the Promissory Note.
6. That a foreclosure should not be decreed where the mortgagee is not in possession of the
notes secured thereby. Chestnut v. Robinson, 85 Fla. 87 (1923).
7. Therefore, until such time that the Plaintiff can establish ownership and possession of the
original Promissory Note at issue, by either providing this Court with the original or by
reestablishing the Note pursuant to Florida Statues, § 673.3091, a foreclosure or mortgage
action related to said Note should not commence.
8. The Lis Pendens filed in this matter should be dissolved as it fails to comply with Florida
Statute § 48.23(1)(a), which requires that “the time of institution of the action” be contained
therein, and such information in not provided. As such, the Lis Pendens should be
dissolved. A copy of the subject Lis Pendens is attached hereto as Exhibit “B”.
WHEREFORE, the Defendants, GIUSEPPE MANNARINO, ANTHONY MANNARINO,
MARIA MANNARINO, and DANIELLE MANNARINO, requests that this Court grant their
Motions and enter an Order dismissing the Plaintiffs Complaint in its entirety and dissolving the
aforementioned Lis Pendens and grant any and further just relief that this Court may deem proper.CERTIFICATE OF SERVICE
J HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
facsimile and U.S. Mail to Marshall C. Watson, Esq. of the Law Offices Of Marshall C. Watson,
‘ /
P.A., 1800 N.W. 49" Street, Suite 120, Fort Lauderdale, Florida 33309, on this 2p day of
March, 2008.
LAW OFFICES OF PHILIP L. SCHWARTZ, P.A.
Philip L. Schwartz, Esq.
2000 Glades Road, Suite 208
Boca Raton, FL 33431
Q
ebert Mf. Lewis, Esq.
Florida Bar No. 628689
Gary L. White, Esq.
Florida Bar No. 036707IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
, CASE NO.: /
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION, AS TRUSTEE, 502008 CA 0023 0 OXXXX MB
Plaintiff,
vs.
GIUSEPPE MANNARINO; MORTGAGE ; COPY
ELECTRONIC REGISTRATION
SYSTEMS, INC, AS NOMINEE FOR RECEIVED FOR FILING
AUDIRECT, INC. DBA NATIONS HOME
LENDING CENTER; UNITED STATES; JAN 2 4 2698
VERSAILLES AT | WELLINGTON SHARON A. BOCK
HOMEOWNERS ASSOCIATION, INC; CLERK 8 COMPTROLLER
ANTHONY MANNARINO; DANIELLE CIRCUIT CIVIL DIVISION
MANNARINO; MARIA MANNARINO;
JOHN DOE; JANE DOE AS UNKNOWN
TENANT (8) IN POSSESSION OF THE
SUBJECT PROPERTY,
Defendants.
SEES oes igh toe eee
COMPLAINT
‘The Plaintiff, JEMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS TRUSTEE,
sues the Defendants named in the caption hereof and alleges:
COUNT T
1. This is an action to reestablish a promissory note under Section 673.3091 Florida Statutes.
2. OnNovember 21, 2005 at PALM BEACH County, Florida, GIUSEPPE MANNARINO-
executed and delivered to 4UDIRECT, INC. DBA NATIONS HOME LENDING CENTER, a
promissory note in the principal amount of $ 732,715.00.
3. Plaintiff is the owner of said note.
4. — The original promissory note was lost or destroyed subsequent to Plaintiff's acquisition thereof,
the exact time.and manner of said loss or destruction being unknown to Plaintiff.
5. Plaintiff was in possession of the promissory note and was entitled to enforce it when loss of
possession occurred.
6. The loss of possession was not the result of a transfer by Plaintiff or a lawful seizure.
EXHIBIT "A"
08-028457. Plaintiff cannot reasonably obtain possession of the promissory note because its whereabouts
cannot be determined. Said note is not in the custody or control of Plaintiff.
8. The Defendants named in this Complaint are the only persons known to Plaintiff who are
interested for or against reestablishment of the subject note.
9. Plaintiff agrees to the entry of a Final Judgment of Mortgage Foreclosure requiring it indemnify
and hold harmless the Defendants obligor(s) of the promissory note by reason ofa claim by
another person/entity attempting to enforce the lost note herein.
WHEREFORE, Plaintiff demands this court re-establish the Lost Promissory Note.
cOUNT II
10, ‘This is an action to foreclose a mortgage on real property in PALM BEACH County, Florida.
11, OnNovember 21, 2005, GIUSEPPE MANNARINO executed and delivered a promissory note
and GIUSEPPE MANNARINO AND ANTHONY MANNARINO AND DANIELLE
MANNARINO AND MARIA MANNARINO executed and delivered a Purchase Money
Mortgage securing payment of the same to MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC., AS NOMINEE FOR 4UDIRECT, INC. DBA NATIONS HOME
LENDING CENTER, which mortgage was recorded in the Official Records Book 19638, Page
1131, of the Public Records of PALM BEACH County, Florida and which mortgaged the
property described therein, then owned by and in possession of said mortgagor. A copy of the
mortgage are attached hereto and made a part hereof.
12. Plaintiff is the owner of said note.
13. Defendant(s), GIUSEPPE MANNARINO AND ANTHONY MANNARINO AND
DANIELLE MANNARINO AND MARIA MANNARINO, own(s) the property.
14. There has been a default under the note and mortgage held by Plaintiff in that the payment due
October 01, 2007 and all subsequent payments have not been made. Plaintiff declares the full
amount due under the note and mortgage to be now due.
15. All conditions precedent to the filing of this action has been performed or has occurred.
16. There is now due, owing and unpaid to the Plaintiff as of the date of the filing of this complaint
the following amounts on principal of said note and mortgage: unpaid principal
balance: $ 732,715.00, plus interest, escrow, title search expenses for ascertaining necessary
parties to this suit, title search, title exam, filing fee, and attorneys fees and costs.
17. Plaintiff has obligated itself to pay the undersigned attorneys a reasonable fee for their services
herein, Pursuant to the loan documents Plaintiff is entitled to an award of attorneys fees.
18. Defendants, JOHN DOE and JANE DOE, as Unknown Tenant(s) in possession of the subject
property, may claim some interest in or lien upon the subject property arising from being in actual
possession of same, but interest, if any, is subject and inferior to the lien of Plaintiff's mortgage.
08-0284519. The Defendant, UNITED STATES may claim some interest in or lien upon the subject property
by virtue of FEDERAL TAX LIEN, which is recorded at Official Records Book 20409, Page 192
of the Public Records of PALM BEACH County. Said interest, if any, is subject and inferior to the
lien of Plaintiff's mortgage. ‘
20. The Defendant, VERSAILLES AT WELLINGTON HOMEOWNERS ASSOCIATION,
INC. may claim some interest in or lien upon the subject property by virtue of Claim of Lien,
which is recorded at Official Records Book 21659, Page 1693 of the Public Records of PALM
BEACH County. Said interest, if any, is subject and inferior to the lien of Plaintiff's mortgage.
Additionally, The Defendant, VERSAILLES AT WELLINGTON HOMEOWNERS
ASSOCIATION, INC., may claim some interest in or lien upon the subject property by virtue of
any assessments pursuant to FL Statute 720.3085.
21. The Defendant, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS
NOMINEE FOR 4UDIRECT, INC. DBA NATIONS HOME LENDING CENTER may claim
some interest in or lien upon the subject property by virtue of Mortgage, which is recorded at
Official Records Book 19638, Page 1155 of the Public Records of PALM BEACH County. Said
interest, if any, is subject and inferior to the lien of Plaintiff's mortgage.
WHEREFORE, Plaintiff prays as follows:
(a.) That this Court will take jurisdiction of this cause, the subject matter and the parties hereto.
(b.) That this Court ascertain and determine the sums of money due and payable to the Plaintiff from
the Defendant(s), including without limitation principal, interest, advances, attomey fees, and
costs pursuant to the loan documents.
(c.) That the sum of money found to be due as aforesaid be decreed by this Court to be a lien upon the
lands described in Plaintiff's mortgage.
(d.) That such lien be foreclosed in accordance with the rules and established practice of this Court,
and upon failure of the Defendants to pay the amount of money found to be due by them to the
Plaintiff, the said land be sold to satisfy said lien.
(c.) That this Court decree that the lien of the Plaintiff is superior to any and all right, title or interest
of the Defendants herein or any person or parties claiming by, through or under them since the
institution of this suit.
(f.) That all right, title or interest of the Defendants or any person claiming by, through or under them
be forever barred and foreclosed.
08-02845(g.) That this Court grants general relief in this cause as in its discretion might be just and proper
including, but not limited to, a deficiency judgment, except where a discharge is applicable, if the
proceeds of the sale are insufficient to pay Plaintiff's claim.
/
Law Offices of Marshall C.Watson, P.A.
1800 N.W. 49™ Street, Suite 120
Fort Lauderdale, FL 33309
Telephone: (954) 453-0365
(800) 441-2438
Facsimile: (954) 771-6052
By: lye 4B
Tenia Hanter, Esq.
Bar Number: 0016635
Andrew Scolaro
FBN 44927
08-02845' '
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
CASE NO.:
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION, AS TRUSTEE,
Plaintiff, 502008 CA 00230 OXXXX NB
: nw
GIUSEPPE MANNARINO; MORTGAGE : COPY
ELECTRONIC REGISTRATION
SYSTEMS, INC, AS NOMINEE FOR RECEIVED FOR FILING
4UDIRECT, INC. DBA NATIONS HOME on
LENDING CENTER; UNITED STATES; JAN 2.4 2068
VERSAILLES AT WELLINGTON SHARON RF.
HOMEOWNERS ASSOCIATION, INC.; CLERK & COMP?
ANTHONY MANNARINO; DANIELLE CIRCUIT CIV
MANNARINO; MARIA MANNARINO;
JOHN DOE; JANE DOE AS UNKNOWN
‘TENANT (S) IN POSSESSION OF THE
SUBJECT PROPERTY,
Defendants.
SS
NOTICE OF LIS PENDENS
TO THE ABOVE STYLED DEFENDANT: '§ AND ALL OTHERS WHOM IT MAY CONCERN:
YOU ARE HEREBY NOTIFIED of the institution of this action by Plaintiff against you seeking
to foreclose a mortgage on the following property in Palm Beach County, Florida:
LOT 350, VERSAILLES P.U.D., ACCORDING TO THE PLAT THEREOF
RECORDED IN PLAT BOOK 93, PAGE 17, PUBLIC RECORDS OF PALM
BEACH COUNTY, FLORIDA.
including the buildings, appurtenances, and fixtures located thereon.
Law Offices of Marshall C.Watson, P.A.
1800 N.W. 49™ Street, Suite 120
Fort Lauderdale, FL 33309
Telephone: (954) 453-0365
(800) 441-2438
Facsimile: (954) 771-6052
wy on
Tenia Hunter, Esq.
Bar Number: 0016635
ndrew Scolaro
a FBN 44927
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IN THE CIRCUIT COURT OF THE 15 th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JP MORGAN CHASE BANK, NATIONAL CASE NO.: 50 2008 CA 00 2301 XXXXMB ASSOCIATION, AS TRUSTEE, - Division: AW Plaintiff, vs. GIUSEPPE MANNARINO, et al, Defendants. / DEFENDANT, GIUSEPPE MANNARINO, ANTHONY MANNARINO, MARIA MANNARINO, AND DANIELLE MANNARINO’S MOTION TO DISMISS PLAINTIFF’S COMPLAINT MOTION TO porte LIS PENDENS COMES NOW, the Defendants, GIUSEPPE MANNARINO, ANTHONY MANNARINO, MARIA MANNARINO, and DANIELLE MANNARINO (hereinafter “Defendants”), by and through their undersigned attorneys, hereby files this their Motion To Dismiss Plaintiff's Complaint and Motion To Dissolve Lis Pendens filed by JP MORGAN Chase Bank, National Association, As Trustee and in support thereof states as follows: He On or about March 8, 2008, the Defendants were served with Plaintiff, JP MORGAN CHASE BANK, NATIONAL ASSOCIATION, AS TRUSTEE’S, two-count Complaint. See Complaint attached hereto as Exhibit “A”. 2. That Count I of the Plaintiff's Complaint seeks the reestablishment of a promissory note, purportedly executed by the Defendant, GIUSEPPE MANNARINO. 3. That Count II of the Plaintiffs Complaint seeks to foreclose a mortgage on real property owned by the Defendants, located in Palm Beach County, Florida. 4. That Plaintiff's Complaint should be dismissed in its entirety, since the Plaintiff has failed to allege its capacity and furthermore, it can not be determined in what state it is incorporatedthereunder. There is no such corporation listed in Florida, within the Department of State, and if the Plaintiff is a foreign corporation, it must pay the Clerk a fee as a condition precedent to instituting this action. Since, to the best of the undersigned’s knowledge, Plaintiff has not done so and as such, is in violation of Florida Statutes. 5. That Count I of Plaintiff's Complaint should be dismissed on the basis that Plaintiff has not properly established current ownership and possession of the Promissory Note on which - Plaintiff is not seeking relief. This is evident due to Count I in the Plaintiffs Complaint for reestablishment of the Promissory Note. 6. That a foreclosure should not be decreed where the mortgagee is not in possession of the notes secured thereby. Chestnut v. Robinson, 85 Fla. 87 (1923). 7. Therefore, until such time that the Plaintiff can establish ownership and possession of the original Promissory Note at issue, by either providing this Court with the original or by reestablishing the Note pursuant to Florida Statues, § 673.3091, a foreclosure or mortgage action related to said Note should not commence. 8. The Lis Pendens filed in this matter should be dissolved as it fails to comply with Florida Statute § 48.23(1)(a), which requires that “the time of institution of the action” be contained therein, and such information in not provided. As such, the Lis Pendens should be dissolved. A copy of the subject Lis Pendens is attached hereto as Exhibit “B”. WHEREFORE, the Defendants, GIUSEPPE MANNARINO, ANTHONY MANNARINO, MARIA MANNARINO, and DANIELLE MANNARINO, requests that this Court grant their Motions and enter an Order dismissing the Plaintiffs Complaint in its entirety and dissolving the aforementioned Lis Pendens and grant any and further just relief that this Court may deem proper.CERTIFICATE OF SERVICE J HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via facsimile and U.S. Mail to Marshall C. Watson, Esq. of the Law Offices Of Marshall C. Watson, ‘ / P.A., 1800 N.W. 49" Street, Suite 120, Fort Lauderdale, Florida 33309, on this 2p day of March, 2008. LAW OFFICES OF PHILIP L. SCHWARTZ, P.A. Philip L. Schwartz, Esq. 2000 Glades Road, Suite 208 Boca Raton, FL 33431 Q ebert Mf. Lewis, Esq. Florida Bar No. 628689 Gary L. White, Esq. Florida Bar No. 036707IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION , CASE NO.: / JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS TRUSTEE, 502008 CA 0023 0 OXXXX MB Plaintiff, vs. GIUSEPPE MANNARINO; MORTGAGE ; COPY ELECTRONIC REGISTRATION SYSTEMS, INC, AS NOMINEE FOR RECEIVED FOR FILING AUDIRECT, INC. DBA NATIONS HOME LENDING CENTER; UNITED STATES; JAN 2 4 2698 VERSAILLES AT | WELLINGTON SHARON A. BOCK HOMEOWNERS ASSOCIATION, INC; CLERK 8 COMPTROLLER ANTHONY MANNARINO; DANIELLE CIRCUIT CIVIL DIVISION MANNARINO; MARIA MANNARINO; JOHN DOE; JANE DOE AS UNKNOWN TENANT (8) IN POSSESSION OF THE SUBJECT PROPERTY, Defendants. SEES oes igh toe eee COMPLAINT ‘The Plaintiff, JEMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS TRUSTEE, sues the Defendants named in the caption hereof and alleges: COUNT T 1. This is an action to reestablish a promissory note under Section 673.3091 Florida Statutes. 2. OnNovember 21, 2005 at PALM BEACH County, Florida, GIUSEPPE MANNARINO- executed and delivered to 4UDIRECT, INC. DBA NATIONS HOME LENDING CENTER, a promissory note in the principal amount of $ 732,715.00. 3. Plaintiff is the owner of said note. 4. — The original promissory note was lost or destroyed subsequent to Plaintiff's acquisition thereof, the exact time.and manner of said loss or destruction being unknown to Plaintiff. 5. Plaintiff was in possession of the promissory note and was entitled to enforce it when loss of possession occurred. 6. The loss of possession was not the result of a transfer by Plaintiff or a lawful seizure. EXHIBIT "A" 08-028457. Plaintiff cannot reasonably obtain possession of the promissory note because its whereabouts cannot be determined. Said note is not in the custody or control of Plaintiff. 8. The Defendants named in this Complaint are the only persons known to Plaintiff who are interested for or against reestablishment of the subject note. 9. Plaintiff agrees to the entry of a Final Judgment of Mortgage Foreclosure requiring it indemnify and hold harmless the Defendants obligor(s) of the promissory note by reason ofa claim by another person/entity attempting to enforce the lost note herein. WHEREFORE, Plaintiff demands this court re-establish the Lost Promissory Note. cOUNT II 10, ‘This is an action to foreclose a mortgage on real property in PALM BEACH County, Florida. 11, OnNovember 21, 2005, GIUSEPPE MANNARINO executed and delivered a promissory note and GIUSEPPE MANNARINO AND ANTHONY MANNARINO AND DANIELLE MANNARINO AND MARIA MANNARINO executed and delivered a Purchase Money Mortgage securing payment of the same to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR 4UDIRECT, INC. DBA NATIONS HOME LENDING CENTER, which mortgage was recorded in the Official Records Book 19638, Page 1131, of the Public Records of PALM BEACH County, Florida and which mortgaged the property described therein, then owned by and in possession of said mortgagor. A copy of the mortgage are attached hereto and made a part hereof. 12. Plaintiff is the owner of said note. 13. Defendant(s), GIUSEPPE MANNARINO AND ANTHONY MANNARINO AND DANIELLE MANNARINO AND MARIA MANNARINO, own(s) the property. 14. There has been a default under the note and mortgage held by Plaintiff in that the payment due October 01, 2007 and all subsequent payments have not been made. Plaintiff declares the full amount due under the note and mortgage to be now due. 15. All conditions precedent to the filing of this action has been performed or has occurred. 16. There is now due, owing and unpaid to the Plaintiff as of the date of the filing of this complaint the following amounts on principal of said note and mortgage: unpaid principal balance: $ 732,715.00, plus interest, escrow, title search expenses for ascertaining necessary parties to this suit, title search, title exam, filing fee, and attorneys fees and costs. 17. Plaintiff has obligated itself to pay the undersigned attorneys a reasonable fee for their services herein, Pursuant to the loan documents Plaintiff is entitled to an award of attorneys fees. 18. Defendants, JOHN DOE and JANE DOE, as Unknown Tenant(s) in possession of the subject property, may claim some interest in or lien upon the subject property arising from being in actual possession of same, but interest, if any, is subject and inferior to the lien of Plaintiff's mortgage. 08-0284519. The Defendant, UNITED STATES may claim some interest in or lien upon the subject property by virtue of FEDERAL TAX LIEN, which is recorded at Official Records Book 20409, Page 192 of the Public Records of PALM BEACH County. Said interest, if any, is subject and inferior to the lien of Plaintiff's mortgage. ‘ 20. The Defendant, VERSAILLES AT WELLINGTON HOMEOWNERS ASSOCIATION, INC. may claim some interest in or lien upon the subject property by virtue of Claim of Lien, which is recorded at Official Records Book 21659, Page 1693 of the Public Records of PALM BEACH County. Said interest, if any, is subject and inferior to the lien of Plaintiff's mortgage. Additionally, The Defendant, VERSAILLES AT WELLINGTON HOMEOWNERS ASSOCIATION, INC., may claim some interest in or lien upon the subject property by virtue of any assessments pursuant to FL Statute 720.3085. 21. The Defendant, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR 4UDIRECT, INC. DBA NATIONS HOME LENDING CENTER may claim some interest in or lien upon the subject property by virtue of Mortgage, which is recorded at Official Records Book 19638, Page 1155 of the Public Records of PALM BEACH County. Said interest, if any, is subject and inferior to the lien of Plaintiff's mortgage. WHEREFORE, Plaintiff prays as follows: (a.) That this Court will take jurisdiction of this cause, the subject matter and the parties hereto. (b.) That this Court ascertain and determine the sums of money due and payable to the Plaintiff from the Defendant(s), including without limitation principal, interest, advances, attomey fees, and costs pursuant to the loan documents. (c.) That the sum of money found to be due as aforesaid be decreed by this Court to be a lien upon the lands described in Plaintiff's mortgage. (d.) That such lien be foreclosed in accordance with the rules and established practice of this Court, and upon failure of the Defendants to pay the amount of money found to be due by them to the Plaintiff, the said land be sold to satisfy said lien. (c.) That this Court decree that the lien of the Plaintiff is superior to any and all right, title or interest of the Defendants herein or any person or parties claiming by, through or under them since the institution of this suit. (f.) That all right, title or interest of the Defendants or any person claiming by, through or under them be forever barred and foreclosed. 08-02845(g.) That this Court grants general relief in this cause as in its discretion might be just and proper including, but not limited to, a deficiency judgment, except where a discharge is applicable, if the proceeds of the sale are insufficient to pay Plaintiff's claim. / Law Offices of Marshall C.Watson, P.A. 1800 N.W. 49™ Street, Suite 120 Fort Lauderdale, FL 33309 Telephone: (954) 453-0365 (800) 441-2438 Facsimile: (954) 771-6052 By: lye 4B Tenia Hanter, Esq. Bar Number: 0016635 Andrew Scolaro FBN 44927 08-02845' ' IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO.: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS TRUSTEE, Plaintiff, 502008 CA 00230 OXXXX NB : nw GIUSEPPE MANNARINO; MORTGAGE : COPY ELECTRONIC REGISTRATION SYSTEMS, INC, AS NOMINEE FOR RECEIVED FOR FILING 4UDIRECT, INC. DBA NATIONS HOME on LENDING CENTER; UNITED STATES; JAN 2.4 2068 VERSAILLES AT WELLINGTON SHARON RF. HOMEOWNERS ASSOCIATION, INC.; CLERK & COMP? ANTHONY MANNARINO; DANIELLE CIRCUIT CIV MANNARINO; MARIA MANNARINO; JOHN DOE; JANE DOE AS UNKNOWN ‘TENANT (S) IN POSSESSION OF THE SUBJECT PROPERTY, Defendants. SS NOTICE OF LIS PENDENS TO THE ABOVE STYLED DEFENDANT: '§ AND ALL OTHERS WHOM IT MAY CONCERN: YOU ARE HEREBY NOTIFIED of the institution of this action by Plaintiff against you seeking to foreclose a mortgage on the following property in Palm Beach County, Florida: LOT 350, VERSAILLES P.U.D., ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 93, PAGE 17, PUBLIC RECORDS OF PALM BEACH COUNTY, FLORIDA. including the buildings, appurtenances, and fixtures located thereon. Law Offices of Marshall C.Watson, P.A. 1800 N.W. 49™ Street, Suite 120 Fort Lauderdale, FL 33309 Telephone: (954) 453-0365 (800) 441-2438 Facsimile: (954) 771-6052 wy on Tenia Hunter, Esq. Bar Number: 0016635 ndrew Scolaro a FBN 44927